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COMMENTS AND RESPONSE TO COMMENTS ON AUTHORISATION

Substance name: Lead sulfochromate yellow (C.I. Pigment Yellow 34)EC number: 215-693-7CAS number: 1344-37-2Broad information on use applied for (title): Industrial application of paints on metal surfaces (such as machines vehicles, structures, signs, road furniture, coil coating etc.)Consultation number: 0012-03Applicant name: DCC Maastricht B.V. ORConsultation period: 12/02/2014 - 09/04/2014

Reference number and date:

Submitter: Alternative: Attachments:Type Generic name EC

Number

CAS Number

Description of technical alternative

Classification and Labelling

Ref.No: 514Date: 2014/04/08

Affiliation:BehalfOfACompanyType/Role in the supply chain:Downstream UserName of org/company:Pronto Industrial Paints LtdCountry:United Kingdom

SubsInMixture

Proprietary Middle Chrome Colour - Yellow

CLPNot Hazardous

Comment_514_Attachment.doc

Applicants’ response:

1(55)

Applicants reply to comments 513, 514, 515Contributing third party: Pronto Industrial Paints LtdECHA consultation numbers 0012-01, 0012-03, 0012-05

DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34 or PR.104.

DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. The proprietary middle/medium chrome pigments from three multinational manufacturers, evaluated by Pronto Industrial Paints Ltd, lacked the chroma, cleanliness, shade functionality, opacity and dispersibility to be considered viable PY.34 alternatives. In addition to compensate for its lack of shade functionality, these pigments must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment submitted by Pronto Industrial Paints Ltd being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PY.34) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternatives. In other words the proposed alternatives are not able to cover the total volume of PY.34 related to the uses applied for.

DCC notes that the Pronto Industrial Paints Ltd submission supports its application for authorisation for the continued use of PY.34.



Number

CAS Number



Ref.No: 511Date: 2014/04/08

Affiliation:BehalfOfACompanyType/Role in the supply chain:Downstream UserName of org/company:Pronto Industrial Paints Ltd

SubsInMixture

Proprietary Lemon Chrome Colour - Yellow

CLPNot Hazardous


2(55)

Country:United Kingdom

Applicants’ response:Applicants reply to comments 510, 511, 512Contributing third party: Pronto Industrial Paints LtdECHA consultation numbers 0012-01, 0012-03, 0012-05

DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34 or PR.104.

DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. The proprietary lemon chrome pigments from three multinational manufacturers, evaluated by Pronto Industrial Paints Ltd, lacked the chroma, cleanliness, shade functionality, opacity and dispersibility to be considered viable PY.34 alternatives. In addition to compensate for its lack of shade functionality, these pigments must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.


In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternatives. In other words the proposed alternatives are not able to cover the total volume of PY.34 related to the uses applied for.




Number

CAS Number



Ref.No: 490Date: 2014/04/08

Affiliation:BehalfOfACompanyType/Role in the supply chain:Downstream UserName of

SubsOnItsOwn

Anthroquinine Yellow – C.I. Pigment Yellow 195

CLPNot Hazardous


3(55)

org/company:Pronto Industrial Paints LtdCountry:United Kingdom

Applicants’ response:Applicants reply to comments 489, 490, 491Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03 and 0012-05

DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34.

The alternative proposed in this submission, PY.195, is withdrawn from the market and is not commercially available anymore. Therefore not a viable alternative to PY.34.



Number

CAS Number



Ref.No: 487Date: 2014/04/08


SubsOnItsOwn

Benzimidazalone Yellow – C.I. Pigment Yellow 194

82199-12-0

CLPNot Hazardous



4(55)


DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, namely PY.194.

DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PY.194 simply lacks the chroma, shade functionality, opacity and dispersibility to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.


In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternative. In other words the proposed alternative is not able to cover the total volume of PY.34 related to the uses applied for. The raw material availability or lack of process capacity could also impact the availability of the proposed alternative PY.194.




Number

CAS Number



Ref.No: 484Date: 2014/04/08


SubsOnItsOwn

Bismuth Vanadate – C.I. Pigment Yellow 184

112764-76-8

CLPNot Hazardous


5(55)




DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PY.184 simply lacks the chroma, shade functionality, opacity and dispersibility to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.


In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternative. In other words the proposed alternative, PY.184, is not able to cover the total volume of PY.34 related to the uses applied for. Also issues with raw material availability could impact the availability of the proposed alternative, PY.184, as both Bismuth and Vanadium are in limited supply and the global demand for this pigment is increasing.




Number

CAS Number



Ref.No: 470Date: 2014/04/08

Affiliation:BehalfOfACompanyType/Role in the supply chain:Importer

SubsOnItsOwn

Bismuth Vanadate - CI Yellow 184

CLPnot classified


6(55)

Name of org/company:ConfidentialCountry:Confidential

Applicants’ response:Applicants reply to comments 469, 470, 471Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03, 0012-05

DCC has one of the widest ranges of PY.34 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace PY.34 due to the compromises in performance that have to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, namely PY.184 (Bismuth Vanadate).

DCC notes that the comments submitted are in favour of approving the authorization of PY.34 to allow for the continued use of PY.34. In support of this submission, the PY.184 simply lacks the shade functionality, chroma, dispersibility and alkali resistance to be considered a viable PY.34 alternative. In addition, to compensate for their lack of shade functionality, this pigment class must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism. The result is a blended product that results in a reduction of desired pigment properties such as colour saturation and weatherfastness.

We agree to another important aspect of the comment being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 6 times higher compared to PY.34 will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU. The additional processing time required to make the pigment dispersions will also increase energy use and product cost.

The submitted comment does not address the lack of availability for the alternative, however the applicant noted in its AoA that the word-wide demand for Vanadium and Bismuth raw materials for PY.184 is limited while the demand for PY.184 is increasing. This lack of raw material availability and lack of process capacity could impact the availability of the proposed PY.184.The manufacture of PY.184 involves using chemicals that require exacting process controls to protect workers and the environment. The key raw materials sodium vanadate and vanadium pentoxide are acutely toxic. As such the manufacture of PY.184 does not result in a reduction of risk to employees in comparison with PY.34.

DCC notes that this submission supports its application for authorization for the continued use of PY.34.



Number

CAS Number



7(55)

Ref.No: 455Date: 2014/04/08


SubsOnItsOwn


77804-81-0

CLPNot Hazardous




DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PY.180 simply lacks the shade functionality, chroma and opacity to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.





Number

CAS Number



Ref.No: Affiliation: SubsOnItsOw Benzimidazalon 68516- CLP Comment_452_Attachment.do8(55)

452Date: 2014/04/08

BehalfOfACompanyType/Role in the supply chain:Downstream UserName of org/company:Pronto Industrial Paints LtdCountry:United Kingdom

n e Yellow – C.I. Pigment Yellow 155

73-4 Not Hazardous

c



DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PY.155 simply lacks the shade functionality, chroma, durability, opacity and dispersibility to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.


In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternative. In other words the proposed alternative PY.155 is not able to cover the total volume of PY.34 related to the uses applied for. Furthermore, the raw material availability or lack of process capacity could impact the availability of the proposed alternative PY.155.




Number

CAS Number

Description of technical


9(55)

alternative

Ref.No: 447Date: 2014/04/08

Affiliation:BehalfOfACompanyType/Role in the supply chain:ManufacturerName of org/company:ConfidentialCountry:Confidential

chrome antimony titanium buff rutile

68186-90-3

CLPnot classified

Comment_447_Attachment.pdf

Applicants’ response:Applicants reply to comments 446, 447, 448, 449, 450Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03, 0012-05, 0012-07, 0012-09

DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, namely PBr.24.

DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PBr.24 simply lacks the durability to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment, being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PY.34) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

DCC notes that the submission supports its application for authorisation for the continued use of PY.34.



Number

CAS Number



Ref.No: Affiliation: SubsOnItsOw Benzimidazalon 66134- CLP Comment_444_Attachment.do10(55)

444Date: 2014/04/08


n e Yellow – C.I. Pigment Yellow 154

22-5 Not Hazardous

c



DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PY.154 simply lacks the shade functionality, chroma, durability, opacity and dispersibility to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.






Number

CAS Number



11(55)

alternative

Ref.No: 439Date: 2014/04/08


bismuth vanadate

14059-33-7

CLPSTOT Rep. Exp. 2 H373



12(55)

Applicants reply to comments 438, 439, 440, 441, 442Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0021-03, 0021-05, 0012-07, 0012-09



We agree to another important aspect of the comment being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances with prices about 6 times higher compared to PY.34 will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU. The additional processing time required to make the pigment dispersions will also increase energy use and product cost.

The submitted comment does not address the lack of availability for the alternative, however the applicant noted in its AoA that the world-wide demand for Vanadium and Bismuth raw materials for PY.184 is limited while the demand for PY.184 is increasing. This lack of raw material availability and lack of process capacity could impact the availability of the proposed PY.184.The manufacture of PY.184 involves using chemicals that require exacting process controls to protect workers and the environment. The key raw materials sodium vanadate and vanadium pentoxide are acutely toxic. As such the manufacture of PY.184 does not result in a reduction of risk to employees in comparison with PY.34.




Number

CAS Number



Ref.No: 436Date: 2014/04/08

Affiliation:BehalfOfACompanyType/Role in the supply chain:

SubsOnItsOwn


31837-42-0

CLPNot Hazardous


13(55)

Downstream UserName of org/company:Pronto Industrial Paints LtdCountry:United Kingdom



DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PY.151 simply lacks the shade functionality, chroma, durability, opacity, dispersibility and alkali resistance to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.






Number

CAS Number



Ref.No: 433Date:

Affiliation:BehalfOfACompany

SubsOnItsOwn

Isoindoline Yellow – C.I. Pigment Yellow

36888-99-0

CLPNot Hazardous


14(55)

2014/04/08

Type/Role in the supply chain:Downstream UserName of org/company:Pronto Industrial Paints LtdCountry:United Kingdom

139



DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PY.139 simply lacks the shade functionality to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.






Number

CAS Number



15(55)

Ref.No: 430Date: 2014/04/08


SubsOnItsOwn

Chinophthalone Yellow – C.I. Pigment Yellow 138

30125-47-4

CLPNot Hazardous




DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PY.138 simply lacks the shade functionality, durability, opacity and dispersibility to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.


In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternative. In other words the proposed alternative PY.138 is not able to cover the total volume of PY.34 related to the uses applied for. Furthermore, the raw material availability of 8-aminoquinaldine (ie. BASF is the only supplier) or lack of process capacity could impact the availability of the proposed alternative PY.138.


Reference number

Submitter: Alternative: Attachments:Type Generic name EC CAS Descriptio Classificatio

16(55)

and date: Number

Number

n of technical alternative

n and Labelling

Ref.No: 427Date: 2014/04/08


SubsOnItsOwn

Disazo Yellow – C.I. Pigment Yellow 83

5567-15-7

CLPNot Hazardous



17(55)



DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PY.83 simply lacks the shade functionality, durability, opacity, solvent resistance and dispersibility to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.


In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltdalso supports the applicant’s view on the lack of availability for the alternative. In other words the proposed alternative PY.83 is not able to cover the total volume of PY.34 related to the uses applied for. Furthermore, raw material availability of 3,3’-dichlorobenzidine (DCB) or lack of process capacity could impact the availability of the proposed alternative PY.83.




Number

CAS Number



Ref.No: 424Date: 2014/04/08

Affiliation:BehalfOfACompanyType/Role in the supply chain:Downstream UserName of org/company:

SubsOnItsOwn

Monoazo Yellow – C.I. Pigment Yellow 74

6358-31-3

CLPNot Hazardous


18(55)

Pronto Industrial Paints LtdCountry:United Kingdom





We agree to the statement submitted by Pronto Industrial Paints Ltd that especially for the road marking industry, where colour is governed by National Regulations and requiring companies to meet specific certifications, it is even more difficult to replace one substance with another. As the final colour should be within a specified colour box, replacing one component (i.e. pigment) with another component (i.e. pigment) could lead to a mismatch in trying to achieve the desired colour. Changing the Regulation as such or amending the companies certification would be possible but is a long process, increasing costs and is not relevant as a short-term solution.




Number

CAS Number



Ref.No: 420Date: 2014/04/0

Affiliation:BehalfOfACompanyType/Role in

SubsOnItsOwn

PY184 CLPnon hazardous


19(55)

8 the supply chain:Downstream UserName of org/company:ConfidentialCountry:Confidential

Applicants’ response:Applicants reply to comments 419, 420Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03


DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of the submission, PY.184 simply lacks shade functionality, colour strength, dispersibility to be considered a viable PY.34 alternative. In addition, to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment submitted being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 5-6 times higher compared to PY.34) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

In support to the submission, the lack of availability of the proposed alternative PY.184 is not able to cover the total volume of PY.34 related to the uses applied for (i.e. limited supply coupled with the global increase in demand). Also issues with raw material availability (i.e. Bismuth & Vanadium) could impact the availability of the proposed alternative PY.184. The manufacturing process of this alternative, PY.184 requires strict handling procedures of the Vanadium pentoxide or sodium vanadate as well as the control of nitrous oxides which are all highly toxic. In other words, process capacity can also impact the availability of PY.184.




Number

CAS Number



20(55)

Ref.No: 418Date: 2014/04/08

Affiliation:BehalfOfACompanyType/Role in the supply chain:Downstream UserName of org/company:ConfidentialCountry:Confidential

SubsOnItsOwn

Y154 CLPNon hazardous


Applicants’ response:Applicants reply to comments 417, 418Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03


DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of the submission, PY.154 simply lacks the shade functionality, durability, chroma, opacity and dispersibility to be considered a viable PY.34 alternative. In addition, to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment submitted being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substance increases the overall costs by a factor of 4 in order to achieve the required opacity. This ultimately impacts the profitability of the company.

In support to the submission, the lack of availability of the proposed alternative (few major sources) is not able to cover the total volume of PY.34 related to the uses applied for. In addition, issues with raw material availability (i.e. 2-triflouromethylaniline, AABD) could impact the availability of the proposed alternative, PY.154.

In addition, the manufacturing process of this alternative, PY.154 requires special handling of 2-triflouromethylaniline and handling of the amine which could also impact the processing capacity/availability of this alternative.


Referenc Submitter: Alternative: Attachments:21(55)

e number and date:

Type Generic name EC Number

CAS Number



Ref.No: 416Date: 2014/04/08


SubsOnItsOwn




22(55)

Applicants reply to comments 415, 416Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03


DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PY.139 simply lacks shade functionality and dispersibility to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment submitted being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 10 times higher along with additional costs to achieve equal opacity) compared to PY.34 will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

In support to the submission, the lack of availability of the proposed alternative (<10 major sources) is not able to cover the total volume of PY.34 related to the uses applied for. In addition, issues with raw material availability (i.e. Diiminoisoindoline) and limitations of use (i.e. barbituric acid is regulated is some countries) could impact the availability of the proposed alternative, PY.139.




Number

CAS Number



Ref.No: 412Date: 2014/04/08

Affiliation:BehalfOfACompanyType/Role in the supply chain:Downstream UserName of org/company:ConfidentialCountry:

SubsOnItsOwn



23(55)

ConfidentialApplicants’ response:Applicants reply to comments 411, 412Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03


DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of the submission, PY.83 simply lacks the shade functionality, chroma, opacity, dispersibility and rheology to be considered a viable PR.34 alternative. In addition, to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment submitted being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substance increases the overall costs significantly in order to achieve the required opacity. This will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

In support to the submission, issues with raw material availability (i.e. limited suppliers of 3,3’ dichlorobenzidine) could impact the availability of the proposed alternative, PY.83.




Number

CAS Number



Ref.No: 410Date: 2014/04/08

Affiliation:BehalfOfACompanyType/Role in the supply chain:Downstream UserName of org/company:Confidential

SubsOnItsOwn

Y74 CLPnon hazardous


24(55)

Country:Confidential

Applicants’ response:Applicants reply to comments 409, 410Contributing third party: Confidential ECHA consultation numbers 0012-01, 0012-03


DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of the submission, PY.74 simply lacks the shade functionality, durability, opacity and dispersibility to be considered a viable PY.34 alternative. In addition, to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment submitted being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substance increases the overall costs significantly in order to achieve the required opacity. This will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.




Number

CAS Number



Ref.No: 407Date: 2014/04/08


SubsOnItsOwn

Arylamide Yellow – C.I. Pigment Yellow 65

6528-34-3

CLPNot Hazardous


25(55)










Number

CAS Number



Ref.No: 404Date: 2014/04/08


SubsOnItsOwn

Nickel Antimony Titanate Yellow Rutile – C.I. Pigment Yellow 53

8007-18-9

CLPNot hazardous


26(55)

Downstream UserName of org/company:Pronto Industrial Paints LtdCountry:United Kingdom



DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PY.53 simply lacks the chroma, shade functionality, colour strength and dispersibility to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.






Number

CAS Number



Ref.No: Affiliation: SubsInMixtur Chrome 68186- CLP Comment_401_Attachment.do27(55)

401Date: 2014/04/08


e Titanate – C.I. Pigment Brown 24

90-3 Not classified c



DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Pronto Industrial Paints Ltd’s submission, PBr.24 simply lacks the chroma, shade functionality and dispersibility to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality, this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.




Reference number


28(55)

and date: Number

Number


n and Labelling

Ref.No: 377Date: 2014/04/08


Bismuth Vanadate Pigment

GHSH373


Applicants’ response:Applicants reply to comments 376, 377Contributing third party: ConfidentialECHA consultation numbers 0012-01 and 0012-03


DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PY.184 simply lacks the durability, shade functionality to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism. These pigment mixtures result in poorer coverage when applied as paints, causing an increase in the number of coatings required and therefore contributes to the increased emissions of solvent into the atmosphere.

We agree to another important aspect of the comment submitted, being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PY.34) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

DCC notes that this submission supports its application for authorisation for the continued use of PY.34.

Reference number


29(55)

and date: Number

Number


n and Labelling

Ref.No: 360Date: 2014/04/07


Nickel Antimony Titanium

CLPnon toxic




DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PY.53 simply lacks the shade functionality to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment, being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PY.34) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.




Number

CAS Number

Description of technical alternativ


30(55)

eRef.No: 351Date: 2014/04/07


Isoindoline CLPnon toxic









Number

CAS Number



Ref.No: Affiliation: Benzimidazolon CLP Comment_348_Attachment.do31(55)

348Date: 2014/04/07

BehalfOfACompanyType/Role in the supply chain:Downstream UserName of org/company:ConfidentialCountry:Confidential

e Non toxic c


32(55)

Applicants reply to comments 347, 348, 349Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03, 0012-05

DCC has one of the widest ranges of PY.34 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace PY.34 due to the compromises in performance that have to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, namely PY.151 (benzimidazolone yellow).

DCC notes that the comments submitted are in favour of approving the authorization of PY.34 to allow for the continued use of PY.34. In support of this submission, the PY.151 simply lacks the durability, shade functionality, chroma, opacity, dispersibility and alkali resistance to be considered a viable PY.34 alternative. The discolouration in an epoxy resin is just one of many examples that could be demonstrated. In addition, to compensate for their lack of shade functionality, this pigment class must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment, being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PY.34) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU. The additional processing time also increases product cost.

In addition to the increase of costs, the submitted comment also supports the applicant’s view on the lack of availability for the alternative. In other words the proposed PY.151 alternative is not able to cover the total volume of PY.34 related to the uses applied for. Issues with raw material availability or lack of process capacity could impact the availability of the proposed PY.151 alternative.

Due to the fact the alternative is based on an organic pigment, with generally speaking a lower density, the material handling will result in more dust formation, possible product cross-contamination, filter-clogging, increased filter waste generation and contamination of protective clothing. This will result in an increased burden to humans and the environment.




Number

CAS Number



Ref.No: 345Date: 2014/04/07


Bismuth Vanadate

14059-33-7

CLPNon toxic


33(55)

Downstream UserName of org/company:ConfidentialCountry:Confidential





The submitted comment does not address the lack of availability for the alternative, however the applicant noted in its AoA that the world-wide demand for Vanadium and Bismuth raw materials for PY.184 is limited while the demand for PY.184 is increasing. This lack of raw material availability and lack of process capacity could impact the availability of the proposed PY.184.

The manufacture of PY.184 involves using chemicals that require exacting process controls to protect workers and the environment. The key raw materials sodium vanadate and vanadium pentoxide are acutely toxic. As such the manufacture of PY.184 does not result in a reduction of risk to employees in comparison with PY.34.




Number

CAS Number



34(55)

alternative

Ref.No: 315Date: 2014/04/07

Affiliation:BehalfOfACompanyType/Role in the supply chain:ImporterName of org/company:WillCountry:Netherlands

SubsInMixture

Benzimidazolone

31837-42-0

CLPnot classified under CLP regulation



35(55)

Applicants reply to comments 288, 290, 292, 294, 296, 298, 308, 309, 310, 311, 312, 313, 314, 315, 316, 317, 318, 319Contributing third party: Will & Co B.V.ECHA consultation number 0012-01, 0012-03, 0012-05, 0012-07, 0012-09, 0012-11

DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, as well as mixing PY.184 with several organic pigments (PY.110, PY.139, PY.151 and PY.154).

DCC notes that the comments submitted by Will & Co B.V. are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Will & Co B.V.’s submission, mixing the above listed inorganic and organic alternatives is a complex process and at the end the mixture simply lacks the chroma, opacity and colour strength to be considered a viable PY.34 alternative. This Will & Co B.V.’s comment confirms the applicants statement that there is no single pigment which can replace PY.34.

We agree to another important aspect of the comment submitted by Will & Co B.V., being the final cost impact in case an Authorisation is not granted. It is stated that the use of the proposed alternative substances (with prices about 5-7 times higher compared to PY.34) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

In addition to the increase of costs, the applicant’s AoA also addresses issues with respect to the lack of availability of some of the alternatives (PY.184 and PY.139). Also issues with raw material availability or lack of process capacity could impact the availability of the proposed alternatives PY.184, PY.139, PY.151 and PY.154. In other words, the proposed mix of alternatives is not able to cover the total volume of PY.34 related to the uses applied for.

DCC notes that Will & Co B.V.’s submission supports its application for authorisation for the continued use of PY.34.



Number

CAS Number



Ref.No: 309Date: 2014/04/07

Affiliation:BehalfOfACompanyType/Role in the supply chain:ImporterName of org/company:

SubsInMixture

Isoindoline yellow

5590-18-1

CLPnot classified under CLP regulation


36(55)

Will & Co BVCountry:Netherlands

Applicants’ response:Applicants reply to comments 288, 290, 292, 294, 296, 298, 308, 309, 310, 311, 312, 313, 314, 315, 316, 317, 318, 319Contributing third party: Will & Co B.V.ECHA consultation number 0012-01, 0012-03, 0012-05, 0012-07, 0012-09, 0012-11








Number

CAS Number



Ref.No: 290Date: 2014/04/07

Affiliation:BehalfOfACompanyType/Role in the supply

SubsInMixture

Bismuth Vanadates Pigments

14059-33-7

CLPSTOT Rep. Exp. 2 H373


37(55)

chain:ImporterName of org/company:WillCountry:Netherlands

Applicants’ response:Applicants reply to comments 288, 290, 292, 294, 296, 298, 308, 309, 310, 311, 312, 313, 314, 315, 316, 317, 318, 319Contributing third party: Will & Co B.V.ECHA consultation number 0012-01, 0012-03, 0012-05, 0012-07, 0012-09, 0012-11








Number

CAS Number



Ref.No: Affiliation: SubsOnItsOw Bismuth 14059- CLP Comment_283_Attachment.pdf38(55)

283Date: 2014/04/07

BehalfOfACompanyType/Role in the supply chain:ImporterName of org/company:Will & Co B.V.Country:Netherlands

n Vanadates Pigments

33-7 STOT Rep. Exp. 2H373

Applicants’ response:Applicants reply to comments 282, 283, 284, 285, 286, 287Contributing third party: Will & Co B.V.ECHA consultation number 0012-01, 0012-03, 0012-05, 0012-07, 0012-09, 0012-11


DCC notes that the comments submitted by Will & Co B.V. are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of Will & Co B.V.‘s submission, PY.184 simply lacks the shade functionality to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism, less cleaner shades, lost of durability and less opacity.

We agree to another important aspect of the comment submitted by Will & Co B.V. being the final cost impact in case an Authorisation is not granted. It is stated that the use of the alternative substance PY.184 (with prices about 5-7 times higher compared to PY.34) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

In addition to the increase of costs, the applicant’s AoA also addresses issues with respect to the lack of availability of the alternative. In other words, the proposed alternative PY.184 is not able to cover the total volume of PY.34 related to the uses applied for. Also issues with the raw material availability, Bismuth and Vanadium, are foreseen as there is limited supply and the global demand for PY.184 is increasing.There are also major issues in the manufacture of PY.184, such as the handling of the toxic raw materials and the formation of nitrous fumes which can cause harm to workers and the environment. As such, the manufacture of PY.184 also requires special handling controls.




NumbeCAS Numbe

Description of

Classification and

39(55)

r r technical alternative

Labelling

Ref.No: 277Date: 2014/04/07


SubsOnItsOwn

Benzimidazolone, PY151

31837-42-0

GHSNon hazardous

Comment_277_Attachment.docx


40(55)

Applicants reply to comments 269, 276, 277, 278, 279, 280, 281Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03, 0012-05, 0012-07, 0012-09, 0012-11

DCC has one of the widest ranges of PY.34 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace PY.34 due to the compromises in performance that have to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, namely PY.151 (benzimidazolone yellow).

DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, the PY.151 simply lacks the durability, shade functionality, chroma, opacity, dispersibility and alkali resistance to be considered a viable PY.34 alternative. In addition, to compensate for their lack of shade functionality, this pigment class must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances with prices about 3-4 times higher compared to PY.34 will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU. The additional processing time required to make the pigment dispersions will also increase energy use and product cost.

We agree to the statement submitted that especially for the road marking industry, where colour is governed by National Regulations and requiring companies to meet specific certifications, it is even more difficult to replace one substance with another. As the final colour should be within a specified colour box, replacing one component (i.e. pigment) with another component (i.e. pigment) could lead to a mismatch in trying to achieve the desired colour. Changing the Regulation or amending the company’s certification would be possible but is a long process, increasing costs and is not relevant as a short-term solution.

The submitted comments suggest that PY.151 is currently commercially available. But this does not reflect the impact of the increased demand that would result if Authorisation were not granted. In other words the proposed PY.151 alternative is not able to cover the total volume of PY.34 related to the uses applied for. Issues with raw material availability or lack of process capacity could impact the availability of the proposed PY.151 alternative.

Due to the fact the alternative is based on an organic pigment, with generally speaking a lower density, the material handling will result in more dust formation, possible product cross-contamination, filter-clogging, increased filter waste generation and contamination of protective clothing. This will result in an increased burden to humans and the environment.




Number

CAS Number



41(55)

Ref.No: 271Date: 2014/04/07


SubsOnItsOwn

Bismuth Vanadium Tetraoxide, PY184

237-898-0

14059-33-7

GHSPY184 is not classified as dangerous according to Regulation (EC) No.1272/2008.

Comment_271_Attachment.docx

Applicants’ response:Applicants reply to comment 268, 270, 271, 272, 273, 274, 275Contributing third party: ConfidentialECHA consultation number 0012-01, 0012-03, 0012-05, 0012-07, 0012-09, 0012-11




We agree to the statement submitted that especially for the road marking industry, where colour is governed by National Regulations and requiring companies to meet specific certifications, it is even more difficult to replace one substance with another. As the final colour should be within a specified colour box, replacing one component (i.e. pigment) with another component (i.e. pigment) could lead to a mismatch in trying to achieve the desired colour. Changing the Regulation as such or amending the companies certification would be possible but is a long process, increasing costs and is not relevant as a short-term solution.

DCC notes the submission supports its application for authorisation for the continued use of PY.34.

Reference number


42(55)

and date: Number

Number


n and Labelling

Ref.No: 209Date: 2014/04/03


SubsOnItsOwn

MONO AZO HANSA YELLOW

6358-31-2

CLPNot classified




DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PY.74 simply lacks the durability, solvent stability & shade functionality to be considered a viable PY.34 alternative.


We also agree to the submitted comment, that due to the fact the alternative is based on an organic pigment, with generally speaking a lower density, the whole handling will result in more dust formation, possible product cross-contamination, filter-clogging, increased filter waste generation and contamination of protective clothing. In other words an increased burden to human and the environment.


Referenc Submitter: Alternative: Attachments:

43(55)

e number and date:

Type Generic name EC Number

CAS Number



Ref.No: 207Date: 2014/04/03


SubsOnItsOwn

BISMUT VANADATE

14059-33-7

CLPNot classified



44(55)

Applicants reply to comments 206, 207Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03


DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, the PY.184 simply lacks the shade functionality, chroma, dispersibility and alkali resistance to be considered a viable PY.34 alternative. In addition, to compensate for their lack of shade functionality, this pigment class must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism. The result is a blended product that results in a reduction of desired pigment properties such as colour saturation, opacity and weatherfastness.


The submitted comment does not address the lack of availability for the alternative, however the applicant noted in its AoA that the word-wide demand for Vanadium and Bismuth raw materials for PY.184 is limited while the demand for PY.184 is increasing. This lack of raw material availability and lack of process capacity could impact the availability of the proposed PY.184.The manufacture of PY.184 involves using chemicals that require exacting process controls to protect workers and the environment. The key raw materials sodium vanadate and vanadium pentoxide are acutely toxic. As such the manufacture of PY.184 does not result in a reduction of risk to employees in comparison with PY.34.




Number

CAS Number



Ref.No: 190Date: 2014/03/26


SubsOnItsOwn

mono azo hansa yellow

6358-31-2

CLPNot classified

Comment_190_Attachment.PDF

45(55)

ManufacturerName of org/company:ConfidentialCountry:Confidential



DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PY.74 simply lacks the durability & shade functionality to be considered a viable PY.34 alternative.


We also agree to the submitted comment, that due to the fact the alternative is based on an organic pigment, with generally speaking a lower density, the whole handling will result in more dust formation, possible product cross-contamination, filter-clogging, increased filter waste generation and contamination of protective clothing. In other words an increased burden to human and the environment.




Number

CAS Number



Ref.No: 188Date: 2014/03/26


SubsOnItsOwn

Bismut Vanadate

237-898-0

14059-33-7

CLPNot Clasified

Comment_188_Attachment.PDF

46(55)

ManufacturerName of org/company:ConfidentialCountry:Confidential

Applicants’ response:Applicants reply to comment 187, 188Contributing third party: ConfidentialECHA consultation number 0012-01 and 0012-03


DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, the PY.184 simply lacks the shade functionality, chroma, dispersibility and alkali resistance to be considered a viable PY.34 alternative. In addition, to compensate for their lack of shade functionality, this pigment class must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism. The result is a blended product that results in a reduction of desired pigment properties such as colour saturation, opacity and weatherfastness.


The submitted comment does not address the lack of availability for the alternative, however the applicant noted in its AoA that the world-wide demand for Vanadium and Bismuth raw materials for PY.184 is limited while the demand for PY.184 is increasing. This lack of raw material availability and lack of process capacity could impact the availability of the proposed PY.184.

The manufacture of PY.184 involves using chemicals that require exacting process controls to protect workers and the environment. The key raw materials sodium vanadate and vanadium pentoxide are acutely toxic. As such the manufacture of PY.184 does not result in a reduction of risk to employees in comparison with PY.34.




Number

CAS Number



47(55)

alternative

Ref.No: 180Date: 2014/03/20


SubsOnItsOwn

Bismuth Vanadate

14059-33-7

CLPNot Classified



48(55)

Applicants reply to comment 179, 180Contributing third party: ConfidentialECHA consultation number 0012-01 and 0012-03


DCC notes that the comments submitted are in favour of approving the authorization of PY.34 to allow for the continued use of PY.34. In support of this submission, the PY.184 simply lacks the shade functionality, chroma, dispersibility and alkali resistance to be considered a viable PY.34 alternative. In addition, to compensate for their lack of shade functionality, this pigment class must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism. The result is a blended product that results in a reduction of desired pigment properties such as colour saturation, opacity and weatherfastness.


The submitted comment does not address the lack of availability for the alternative, however the applicant noted in its AoA that the word-wide demand for Vanadium and Bismuth raw materials for PY.184 is limited while the demand for PY.184 is increasing. This lack of raw material availability and lack of process capacity could impact the availability of the proposed PY.184.




Number

CAS Number



Ref.No: 178Date: 2014/03/20

Affiliation:BehalfOfACompanyType/Role in the supply chain:ManufacturerName of org/company:

SubsOnItsOwn

Chrome Titanate

68186-90-3

CLPNot Classified


49(55)

ConfidentialCountry:Confidential



DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PBr.24 simply lacks the shade functionality, chroma and colour strength to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment, being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PY.34 will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.




Number

CAS Number



Ref.No: 176Date: 2014/03/20

Affiliation:BehalfOfACompanyType/Role in the supply chain:ManufacturerName of org/company:ConfidentialCountry:

SubsOnItsOwn

Nickel Titanate 68186-90-3

CLPNot Classified


50(55)

ConfidentialApplicants’ response:Applicants reply to comments 175, 176Contributing third party: ConfidentialECHA consultation numbers 0012-01 and 0012-03


DCC notes that this comment submitted is in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PY.53 simply lacks the shade functionality to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.


DCC notes that this comment submission supports its application for authorisation for the continued use of PY.34.



Number

CAS Number



Ref.No: 170Date: 2014/03/11

Affiliation:BehalfOfACompanyType/Role in the supply chain:ImporterName of org/company:ZEUS QUIMICA, S.A.Country:Spain

SubsInMixture

Isoindoline Yellow

253-256-2

36888-99-0

CLPNot Classified


Applicants’ response:51(55)

Applicants reply to comments 169, 170Contributing third party: ZEUS QUIMICA, S.A.ECHA consultation numbers 0012-01, 0012-03

DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, as well as a mixture of PY.74 and PY.139.

DCC notes that the comments submitted by ZEUS QUIMICA, S.A are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of ZEUS QUIMICA, S.A’s submission, the listed mixture of PY.74 and PY.139 simply lacks the solvent stability, light fastness, weather fastness and gloss to be considered a viable PY.34 alternative. In addition, the handling of this mixture needs special attention to control the temperature during milling and is unstable to storage.

We agree to another important aspect of the comment submitted by ZEUS QUIMICA, S.A being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 3 times higher compared to PY.34) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

In addition to the increase of costs, the applicant’s AoA also addresses issues with respect to the lack of availability of some of the alternatives (PY.139). Also issues with raw material availability or lack of process capacity could impact the availability of the proposed alternative PY.139. In other words, the proposed mix of alternatives (PY.74 and PY.139) is not able to cover the total volume of PY.34 related to the uses applied for.

DCC notes that ZEUS QUIMICA, S.A’s submission supports its application for authorisation for the continued use of PY.34.



Number

CAS Number



Ref.No: 168Date: 2014/03/11

Affiliation:BehalfOfACompanyType/Role in the supply chain:ImporterName of org/company:ZEUS QUIMICA,

SubsInMixture

Mono Azo Hansa Yellow

228-768-4

6358-31-2

CLPNot Classified


52(55)

S.A.Country:Spain

Applicants’ response:Applicants reply to comments 167, 168Contributing third party: ZEUS QUIMICA, S.AECHA consultation numbers 0012-01 and 0012-03

DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, as well as a mixture of PY.74 and PY.139.

DCC notes that the comments submitted by ZEUS QUIMICA, S.A are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of ZEUS QUIMICA, S.A’s submission, the listed mixture of PY.74 and PY.139 simply lacks the solvent stability, light fastness, weather fastness and gloss to be considered a viable PY.34 alternative. In addition, the handling of this mixture needs special attention to control the temperature during milling and is unstable to storage.

We agree to another important aspect of the comment submitted by ZEUS QUIMICA, S.A being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 3 times higher compared to PY.34) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

In addition to the increase of costs, the applicant’s AoA also addresses issues with respect to the lack of availability of some of the alternatives (PY.139). Also issues with raw material availability or lack of process capacity could impact the availability of the proposed alternative PY.139. In other words, the proposed mix of alternatives (PY.74 and PY.139) is not able to cover the total volume of PY.34 related to the uses applied for.

DCC notes that ZEUS QUIMICA, S.A’s submission supports its application for authorisation for the continued use of PY.34.



Number

CAS Number



Ref.No: 165Date: 2014/03/11


SubsInMixture

Isoindolinone 226-999-5

5590-18-1

CLPNot Classified


53(55)

ImporterName of org/company:ConfidentialCountry:Confidential

Applicants’ response:Applicants reply to comments 164, 165, 166Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03 and 0012-05

DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, namely PY.184 & PY.110.

DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PY.184 & PY.110 simply lacks the shade functionality, opacity & hiding power to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.

We agree to another important aspect of the comment submitted, being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PY.34 will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.

We also agree to the submitted comment, that due to the fact the alternative is partially based on an organic pigment, with generally speaking a lower density, the whole handling will result in more dust formation, possible product cross-contamination, filter-clogging, increased filter waste generation and contamination of protective clothing. In other words an increased burden to human and the environment.

DCC notes that this submission supports its application for authorisation for the continued use of PY.34].



Number

CAS Number



Ref.No: 161Date: 2014/03/1

Affiliation:BehalfOfACompanyType/Role in

SubsOnItsOwn

Bismuth Vanadate - CI Yellow 184

237-898-0

14059-33-7

CLPNot Classified


54(55)

0 the supply chain:ImporterName of org/company:ConfidentialCountry:Confidential

Applicants’ response:Applicants reply to comments 160, 161, 162, 163Contributing third party: ConfidentialECHA consultation numbers 0012-01, 0012-03, 0012-07, 0012-09




The submitted comment does not address the lack of availability for the alternative, however the applicant noted in its AoA that the world-wide demand for Vanadium and Bismuth raw materials for PY.184 is limited while the demand for PY.184 is increasing. This lack of raw material availability and lack of process capacity could impact the availability of the proposed PY.184.The manufacture of PY.184 involves using chemicals that require exacting process controls to protect workers and the environment. The key raw materials sodium vanadate and vanadium pentoxide are acutely toxic. As such the manufacture of PY.184 does not result in a reduction of risk to employees in comparison with PY.34.


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